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2. Discussion
As directed by section 6015(f), respondent has prescribed
procedures to use in determining whether a relief-seeking spouse
qualifies for relief under section 6015(f). Those procedures are
found in Rev. Proc. 2000-15 (the revenue procedure), 2000-5
I.R.B. 447, modifying and superseding Notice 98-61, 1998-51
I.R.B. 13. Section 7 of the revenue procedure states that it is
effective on January 18, 2000, which precedes David’s submission
to respondent of the Form 8857 on June 13, 2000. Section 4.03 of
the revenue procedure, applicable to a relief-seeking spouse in
Barbara’s situation, provides: “The Secretary may grant
equitable relief under � 6015(f) * * * if, taking into account
all the facts and circumstances, it is inequitable to hold the
requesting spouse liable for all or part of the unpaid liability
or deficiency.” The revenue procedure includes a partial list of
positive and negative factors that will be taken into account in
determining whether to grant full or partial relief and cautions
that no single factor will be determinative of whether equitable
relief will or will not be granted in any particular case. It
states: “Rather, all factors will be considered and weighed
appropriately.”
Petitioners have failed to introduce any evidence showing
the basis for respondent’s rejection of their claim for equitable
relief for Barbara. Nevertheless, the revenue procedure
establishes as factors weighing against equitable relief whether
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